ML19207A229

Regulatory Audit Report Regarding License Amendment Request for Flood Protection Dike Modification

ML19207A229
Person / Time
Site:	North Anna
Issue date:	08/16/2019
From:	Geoffrey Miller Plant Licensing Branch II
To:	Stoddard D Southern Nuclear Operating Co
Miller G, NRR/DORL/LPL2-1, 415-2481
References
EPID L-2018-LLA-0485
Download: ML19207A229 (17)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 16, 2019 Mr. Daniel G. Stoddard Senior Vice President and Chief Nuclear Officer Innsbrook Technical Center 5000 Dominion Blvd.

Glen Allen, VA 23060-6711

SUBJECT:

NORTH ANNA POWER STATION, UNITS 1 AND 2- REGULATORY AUDIT REPORT REGARDING LICENSE AMENDMENT REQUEST FOR FLOOD PROTECTION DIKE MODIFICATION (EPID L-2018-LLA-0485)

Dear Mr. Stoddard:

By letter dated November 19, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18334A106), Dominion Energy Virginia (Dominion), submitted a license amendment request regarding the North Anna Power Station (North Anna or NAPS).

The proposed amendment would revise the licensing basis of North Anna regarding a safety-related flood protection dike.

On July 3, 2019 (ADAMS Accession No. ML19165A017), the U.S. Nuclear Regulatory Commission (NRC) staff issued an audit plan that conveyed intent to conduct a regulatory audit to support its review of the subject license amendment. On July 15 - 17, 2019 the NRC staff conducted the audit at North Anna.

The purpose of the audit was to gain understanding, to verify information, and to identify information that will require docketing to support the proposed licensing action. Based on the audit, Dominion indicated its intent to supplement the LAR. If additional information is needed beyond the supplement, a request for additional information will be issued. The enclosure to this letter provides a report of the NRC staff's audit.

D. Stoddard If you have any questions, please contact me by telephone at (301) 415-2481 or by e-mail at ed.miller@nrc.gov.

5

@ot11',1 G. Edward Miller, Project Manager Special Projects and Process Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-338 and 50-339

Enclosure:

Audit Report cc: Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 REGULATORY AUDIT REPORT DOMINION ENERGY VIRGINIA (DOMINION)

NORTH ANNA POWER STATION LICENSE AMENDMENT REQUEST FLOOD PROTECTION DIKE MODIFICATION DOCKET NOS. 50-338 AND 50-339

1.0 BACKGROUND

By application dated November 19, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18334A106, Dominion Energy Virginia, the licensee, requested the U.S. Nuclear Regulatory Commission (NRC) staff review and approve a proposed amendment which would revise the North Anna Power Station (North Anna), Units 1 and 2 current licensing bases regarding a safety-related flood protection dike.

The NRC staff has performed a detailed review of the proposed LAR. Due to the complexity of the proposed amendment, supporting calculations such as the slope stability analysis, external flood mitigation strategies, risk analysis, and completed design change modifications, the staff had determined that a site visit the North Anna Power Station, Units 1 and 2, can resolve complex technical issues more quickly than several rounds of requests for additional information (RAI). Additionally, face-to-face interactions would allow the staff to review and assess physical aspects of the site subject to the LAR through field walkdowns. The NRC audit plan was sent to Dominion Energy Virginia on July 3, 2019 (ADAMS Accession No. ML19165A017).

The NRC staff conducted the regulatory audit in accordance with the Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, "Regulatory Audits" (ADAMS Accession No. ML082900195).

2.0 SCOPE AND PURPOSE The audit was held on July 15 - 17, 2019. The purpose of the audit was to help the NRC staff better understand the documentation and analysis results through interaction with the licensee's technical experts and to help focus the staff's RAls on those questions where docketed information is needed to complete the review.

Enclosure

3.0 AUDIT TEAM The following NRC staff members participated in the audit:

• Larry Wheeler - Audit Team Lead

• G. Edward Miller - North Anna Project Manager

• Dan Hoang -Technical Reviewer

• Hosung Ahn -Technical Reviewer The following NRC staff members provided support from NRC Headquarters:

• Jeff Circle - Technical Reviewer

• Brian Green -Technical Reviewer 4.0 AUDIT REPORT The purpose of this regulatory audit was to enhance the staff's technical understanding of the LAR as it related to the installed fire protection and domestic water lines and determine if it has negatively affected the safety-related flood protection dike on the North Anna site. The audit focus areas were to better understand related drawings, operator actions (human factors), and show the calculation methodologies, assumptions, and results that were applied by the licensee to reach conclusions in the proposed LAR.

A walkdown of the safety-related flood protection dike area was conducted during the visit to help the NRC staff better understand design changes performed previously to the flood protection dike.

Table 1 provides a list of audit items identified for the audit with a short summary description of how these items were addressed.

Tables 2 and 3 identify participants from the entrance and exit meetings for the audit.

5.0 DOCUMENTS REVIEWED The following key documents were reviewed during the audit:

1. Design Change Modification Package related to the Flood Protection Dike, DCP 07-016, "Fire Protection and Domestic Water System Modifications/North Anna/Units 1 & 2."

2. Design Drawings, N-07016-0-1 FB2A, Sheet 1, "Fire Protection Arrgt Sh-1 North Anna Power Station."

3. Other physical arrangement drawings of the areas of the Protection Dike.

4. Calculation 25161-G-060, "Slope Stability Analysis for Flood Protection Dike, Revision 1, Bechtel Power Corporation."

5. SAR Change Number NAPS-UCR-2013-004.

6. Bechtel Specification 25161-009-3PS-CE02-Q0001.

7. Field Completed work copy of Procedure: GMP-C-102, "Excavation and Backfill."

8. Field Completed work copy of Procedure: GMP-C-174, "Flood Wall Dike Repair."

9. Field Completed work copy of Procedure: 1-PT-9.3.

10. Design Drawing 11715-FY-8AG.

11. Calculation Package: DC 88-14-3.

12. AMEC Report dated 2/1/2013

13. Drawing and/or sketch that is shown the actual location of the 12" and 2" pipe to the west slope and to the top of the slope.

6.0 CONCLUSION

The purpose of the audit was to gain understanding, to verify information, and to identify information that will require docketing to support the proposed licensing action. As a result of the audit, Dominion indicated its intent to supplement the LAR. If additional information is needed beyond the supplement, a request for additional information will be issued. The enclosure to this letter provides a report of the NRC staff's audit.

Date: August 16, 2019

Table 1 Items Identified During the Audit Item Regulatory NRC Question /Request: Audit Response Item Closed to:

1. Bases for the Audit Question?

1 Understanding From the LAR - The section of external flood The fire protection and domestic water piping Closed to audit- no and protection dike of concern is about 350 feet long. Is run parallel along the flood dike for the entire future action Background this the approx. length of the fire protection system length. So the length of the piping is required.

(FPS) and domestic water system (DWS) lines, within approximately the same as the dike. The the safety related (SR) dike. Provide a drawing following project drawings show the piping detailing dimensions, if available. routing, including the buried depth.

Provide a general list of materials within the dike area N-07016-0-1 FB41 D, Domestic Water System

- pipe fittings, valves, post indicating valves (PIVs), fire N-07016-0-1FB101 C, Underground Fire hydrants, thrust blocks, etc.

Protection System Sh.3 N-07016-0-1SSD18C, Flood Protection Dike Provide as-built drawings showing that the new FPS and DWS lines are below the 5'0". Earthwork Plan N-07016-0-1SSl15Q, Small Bore Piping Isometric - Domestic Water System N-07016-0-1SSl15R, Small Bore Piping Isometric - Domestic Water System N-07016-0-1SSl15S, Small Bore Piping Isometric - Domestic Water System N-07016-0-1SSl18AD, Large Bore Piping Isometric - Fire Protection System N-07016-0-1SSl18AE, Large Bore Piping Isometric - Fire Protection System N-07016-0-1SSl18AG, Large Bore Piping Isometric - Fire Protection System There are no valves located within the dike.

Valves are located on the north and south ends beyond the diked area of concern.

Approximate fittings can be determined using the isometric drawings listed above. The fire protection isometrics show 9 elbows from the north side to south side connection points.

Item Regulatory NRC Question /Request: Audit Response Item Closed to:

Bases for the Audit Question?

See also response to auestion 15.

2 NFPA Code Provide documentation of FPS and DWS pressure Documentation of the test plan and Closed to future and ASME testing after installation (within the dike area), and if completed test procedures are provided. supplemental letter.

Code B31.1 possible, indicate what was the approx. test Testing was performed in accordance with pressures? applicable design standards. The fire protection piping within the flood dike was hydrostatically tested at 235 psig, in accordance with NFPA 24, Standard for the Installation of Private Fire Service Mains and their Appurtenances, 2007 edition as referenced in DCP 07-016.

An in-service leak test was performed for the domestic water piping in accordance with section 312.5 of the International Plumbing Code, 2006 edition, as described in DCP 07-016. This is estimated to be a pressure between 60 - 70 psiQ.

3 GDC 2 and DCP 07-016 (3.8, page 11/27) states that the FPS has 11715-PX-1-HB, Addendums OOB and OOC, Closed to audit - no SRP 3.2.1, been seismically reviewed. Provide calculations Seismic Analysis of Underground Fire future action Seismic 11715-PX-1-HB, CE-1773, CE-1779 or other Protection Piping, were prepared in support required.

Classification documentation acceptance of the review. Clarify of DCP 07-016, and are provided. In whether the DWS line have a seismic review/analysis since it was located within a seismically qualified dike. addition, the calculations reference Addendum OOA, CE-1773 and CE-1779 were also provided. The domestic water line was not reviewed for seismic qualification.

4 SRP 18.0, DCP 07-016 (3.8 page 12/27) states that the dike is in This is true for the entire run on the FPS line Closed to audit - no Human factors the open and supports the PA fence which is within the dike. future action engineering continuously under surveillance and readily observed required.

and corrected before the FPS would fail from becoming unsupported by the solid in the dike. Is this true for the whole -350 feet of FPS line within the dike or just part of the buried lines?

Item Regulatory NRC Question /Request: Audit Response Item Closed to:

1. Bases for the Audit Question?

5 SRP 18.0, DCP 07-016, Section 3.31, "training," did this section No. The design change did not require any Closed to audit- no Human factors require non-licensed operators (outside rounds - NLO) changes to Operator rounds or Security future action engineering and security patrols to now be aware of possible patrols related to the awareness of leaking required.

leaking pipes in the area of the new FPS/DWS lines? pipes within the flood dike.

6 SRP 18.0, 10 CFR 50.59 (page 15/17) states that if a failure of No. The 50.59 states that a loss of pressure Closed to future Human factors the DWS line would be reported to the main control in the domestic water system would be supplemental letter engineering room (MCR) in a timely manner - did the low pressure readily identifiable (toilets, drinking fountains, alarm response get revised to state that a possible etc.) and reported promptly. There is no low cause of low DWS pressure that a buried line in the pressure alarm response procedure for SR dike has failed. Are there any immediate actions to domestic water. The associated well houses begin walkdowns of the SR dike area first or ASAP? are inspected during daily Operator rounds 10 CFR 50.59/72.48 supplemental (page 5/7) -has (1-LOG-6E provided) for loss of level or good discussion of FPS/DWS of piping failures pressure. The log verifies the level within (double - ended breaks to small leaks. associated well house hydropneumatic tanks

- states that DWS piping would be identified is visible within the gauge, and pressure is quickly? greater than 45 psig and less than 85 psig.

What directs operators to look in the area of the SR dike first? There were no changes to annunciator Are isolation valves for the FPS and DWS indicated response or other procedures which direct an in any off normal instruction (ONI) for quick isolation inspection of the flood dike first.

to orevent damaae to the SR dike?

7 SRP 2.4.10, Provide drawings that indicate where the dike is Drawings have been provided showing the Closed to audit - no flooding - located on FSAR drawing 9.5-1 and DCP drawing location of the dike. future action protection 2.1-1E. required.

requirements

-Drawing details missing from the LAR 8 SRP 18.0, From the LAR (break or leak timely identifications): Closed to future Human a. Security would notice significant differences a. Patrols are performed several times a day. supplemental letter.

factors (wetness or pooling) in the appearance of the Weekly camera inspections are engineering flood protection dike during routine patrols performed which provides an opportunity performed several times each day. How often to inspect the western slope of the dike.

are patrols directly over this FPS/DWS pipe,

Item Regulatory NRC Question /Request: Audit Response Item Closed to:

1. Bases for the Audit Question?

done with cameras, how close are the Camera capabilities also exist for the inspections done to the piping? western slope of the dike.

b. The flood protection dike is landscaped at least b. Landscaping every 6 months help prevent twice a year. Explain how is landscaping every excessive or extreme growth on the dike 6 months considered here? bank, allowing for a better ability to identify leaks. In addition, individuals in the area would be expected to identify abnormal conditions.

C. Small leaks of both pipe sizes would be c. Small leaks would take some time before detected during the annual flood protection dike a large portion of the dike is washed out.

inspection. How is inspection every 365 days The annual inspection provides an considered here? opportunity to identify an anomalous condition associated with the dike (such as water pooling). Security capabilities also provide opportunities to identify small leaks before becoming a significant issue as discussed above

d. A fire protection system piping leak or rupture d. No changes have been made to the would result in increased cycling of the fire annunciator response procedures.

protection hydropneumatic tank level and Operations monitor the fire protection pressure, which are monitored daily by hydropneumatic tank once per shift per Operations. Furthermore, the pressure 1-LOG-6E. Tank level is verified between maintenance pump would be cycling to 10 and 80 % in the level gauge, and maintain the dropping tank pressure. Have pressure is verified between 104 psig and alarm response procedures been revised to 120 psig.

include looking in the SR dike area for leaks?

e. Significant leakage (>30 gpm) [gallons per minute] would auto start a main fire pump and e. NA (no question) alert the operators in the control room, triaaerinQ an investigation.

Item Regulatory NRC Question /Request: Audit Response Item Closed to:

Bases for the Audit Question?

f. Operators perform quarterly and annual f. Operators in the area provide another periodic tests which cycle the fire protection means to identify anomalous conditions.

system valves at the ends of the flood protection dike, which provides an additional opportunity to observe signs of leakage on the western bank of the flood dike. How is this considered?

g. The domestic water system usage is g. This is another opportunity to identify monitored monthly under a chemistry leakage of the domestic water system.

procedure and is trended by a System Operator rounds per 1-LOG-6E provide daily checks of well house tank level and Engineer. A leak investigation would pressure as described in Q6.

commence if the usage exceeds 600,000 gallons monthly (estimated to be equivalent to a 14 gpm leak based on normal usage). How is this considered?

9 GDC2 LAR Att.1, Sec. 2.2 As discussed in the original slope stability Closed to future The attachment says that the dike slope stability calculation, CE-0638, the top elevation of the supplemental letter.

analysis performed with the probable maximum dike (271 ft MSL) was chosen to provide flood (PMF) lake level of 264.2 ft mean sea level adequate freeboard above the PMF water (MSL) shows adequate factors of safety. Generally, elevation plus the wave run-up associated the dike slope stability analysis must also consider with the 2 yr wind speed. However, the wave the effects of wave runup which are persistent run-up was not considered critical in regards during the lake flooding as the period of wave is to the slope stability analysis and was not much shorter than the period of flood (i.e., few considered. The excerpt from the UFSAR, seconds versus several hours). section 2A.2.7, indicates that the intake structure for units 3 and 4 is protected by a Therefore the NRC staff requests the following two point of land, making wind effects non-items: (i) Present the dike slope stability modeling, critical. As noted on the site drawings, the including discussion of model setup, assumptions, flood dike is actually located behind (i.e.,

and model input/output; (ii) Discuss the effects of farther back from the lake) the Unit 3 and 4 the increased flood level due to the estimated wave intake structure/screen wall, which would runup of 3.1 ft (as reported in the UFSAR) on the

Item Regulatory NRC Question /Request: Audit Response Item Closed to:

1. Bases for the Audit Question?

dike stability analysis, or justify why the effects of logically render overtopping or wind effects wave runup is not applicable here. moot.

10 SRP 2.4.10, LAR Att. 1, Sec. 3.0 Closed to future flooding . supplemental letter.

protection (a) For PRA analysis on page 8, the applicant (a) A boundary condition for this analysis was requirements assumed that a failure of the fire protection pipe selected to determine a conservative rainfall

- occurs within seven days of a significant rainfall frequency (i.e., a 1-in-1000-year event) that Drawing event and that at least 15-inches of rain falls in less would led to a flood dike failure. NOAA data details than 72 hours3 days <br />0.429 weeks <br />0.0986 months <br />. However, the duration of design was used to determine the bounding rainfall missing from basis rainfall for the Lake Anna PMF outlined in the event frequency. Dominion assumed that the the LAR. UFSAR is 9 days: 3 days for 40% probable selected frequency was not the PMP or PMF maximum precipitation (PMP) as a pre-storm, 3 as a way to bias the analysis in the days for no-rain, and then 3 days for PMP. Also, the conservative direction.

3-day PMP depth at the Lake Anna basin reported in the UFSAR is 30.65 inches. Address how this design basis PMP rainfall scenario changes the result of the PRA analyses.

(b) Dominion's analysis asserts that the (b) (Risk Analysis, page 8): The leak condition could rupture of the fire protection (FP) pipe does lead to a subsidence of the dike and in turn could not depend on a significant rainfall event.

create a rupture of 12 inches fire protection pipe During the audit, the staff raised concerns and dike. In this case, rainfall and pipe failure regarding whether the potential for a small events are dependent and the failure probability of leak condition from the FP pipe leaking down this scenario would be increased compared to the to the drainpipe to cause subsidence/voiding applicant's estimate under an independent around the drainage pipe leading to a dike assumption as described on page 10. Please failure during a flood event. Dominion address the potential failure of the dike rupture responded that this type of dependent event followed by a failure of drainpipe and fire protection was excluded from the analysis because pipe in a dependent manner during an extreme there are multiple ways that the small FP pipe rainfall event, or justify why this type of combined leakage could be detected before the rupture failures is not plausible. of the dike.

11 GDC 2 and Provide any documentation that the licensee has The fill placement and compaction was Closed to future SRP 3.2.1, met: (1) Section 3.4 "Fill Placement and performed per specification 25161-009-3PS- supplemental letter.

Seismic Compaction Requirements" and (2) Section 4.0, CE02-Q0001 (Technical Specification for Classification "Quality Assurance and Testing Requirements" of Excavation, Backfill and Compaction of

Item Regulatory NRC Question /Request: Audit Response Item Closed to:

Bases for the Audit Question?

SRP 2.4.10, Specification No. NAl-003, Revision 1 dated Trenches for Pipe and the requirements for flooding September 21, 1989. As indicated in the Calculation loose lift thickness and required compaction protection package 25161-G-060, dated May 6, 2011, for 2011 are the same between Section 3.7 of 25161-requirements modification works. 009-3PS-CE02-Q0001 and NAl-003. The

- Drawing results of the soil prequalification testing and details soil placement testing are documented in the missing from AMEC Compilation Testing Report for Utility the LAR. Backfill Testing Flood Protection Dike. The AMEC report documents that the fill placement met the requirements of specification 25161-009-3PS-CE02-QOOO 1.

It details the proctor sample, measured moisture content, measured dry-density, required dry-density, and specified moisture content range of the material at the point the nuclear density gauge measurement was taken. Additional comments regarding the passing or failure of the specific tests and relevant observations were also included in the AMEC report.

12 SRP 2.4.10, In the AMEC Report (dated 2/1/2013): Soil compaction specifications are Closed to future flooding established based on the type of soil and supplemental letter.

protection

• There are 7 tests that appear to be missing in the proposed use, and the moisture-density requirements report (pages 28 - 32, and 56 - 57). Please relationship developed with either the

- provide the missing test data Standard Proctor (ASTM 0698) or Modified Drawing Proctor (ASTM 01557) test. These tests details

• There are 29 results that were "outside" of the differ by the amount of compaction energy appear to be test specified range - Please provide the missing from applied to a specified soil volume, with the corrective action, if any, that had been taken by the LAR higher compaction energy test (Modified)

Dominion.

resulting in a higher dry density in the

• Please provide mapped out test locations that compacted specimen. The optimum moisture were addressed in the report content is the water weight to dry soil weight ratio (%) at which the compacted soil specimen achieves its maximum dry density

Item Regulatory NRC Question /Request: Audit Response Item Closed to:

1. Bases for the Audit Question?

relative to the compaction energy input of the specific test. The important factor to note here is "relative to the compaction energy",

because a properly placed fill can experience higher compaction energy during construction than in the lab. Typically, the compaction specification indicates a moisture content range around the optimum point for the given material so the contractor has an idea of what soil conditions will provide the best compaction/construction behavior. When the material is tested, typically with a nuclear density gauge, the in-situ moisture content and density is measured, and the dry-density is computed. Meeting the specified in-situ dry density is the primary objective and as long as that is achieved, the construction is acceptable. The specification for the Flood Dike construction, NA-SPEC-OOO-NAl-0003 acknowledges this in section 3.4.2 "Compaction Requirements," subsection 3.4.2.3 that states, "The moisture content in itself is not considered most critical to the performance of the completed dike. The compact percentage is the critical item and the specified moisture range is only intended as a guideline to achieve adequate compaction." A table listed in this section indicates that when the percentage compaction is 95% or greater and falls outside the listed moisture content range, the testing agency representative is to notify Virginia Power Engineering. The testing

Item Regulatory NRC Question /Request: Audit Response Item Closed to:

Bases for the Audit Question?

agency noted on the inspection reports provided to the owner when the moisture was "outside the specified range". No corrective measures would be necessary as long as the measured dry-density in the field met the specifications.

13 SRP 2.4.10, Please provide the dimension from the center line of Based on the description provided in the Closed to future Flooding the 12" FP piping to the west side of the dike. installation procedure (N3-FA-001-WP-012- supplemental letter.

protection 00), the centerline of the 12" FP piping is requirements approximately 4 feet west of the western of

- the dike crest.

Drawing details (Per the installation procedure N3-FA-001-missing from WP-012-00, a trench was excavated within the LAR. the dike about 4.5 feet from the top of the west side of dike, extending 10 ft into the dike with a 1/1 slope on the eastern edge. A 3 foot by 3 foot trench was dug into the floor of the excavation, about 6 feet in from the western edge. A thin bedding layer was compacted on the base of the trench and the 12" FP piping placed on the bedding.

Sections A - E on project drawing N-07016-0-1 SS018C, Rev.1 show the FP piping placed on the bedding layer in the center of the 3 foot by 3 foot trench (7.5' off the western edge from the top of the trench). This would indicate the centerline of the FP piping is directly below the slope area of the dike, approximately 4 feet west of the western edge of the dike crest. Horizontally from the bottom of the dike slope, the FP line is approximately 11 feet east.

Item Regulatory NRC Question /Request: Audit Response Item Closed to:

Bases for the Audit Question?

14 SRP 2.4.10, Please provide the original (hard copy) of DC 88 Files were presented to the NRC for review. Closed to audit- no flooding 3 (proprietary) to reviewed during the onsite audit future action protection required.

requirements.

15 UFSAR 9.5.1 The LAR, Page 6 states that the fire line has a least a. UFSAR Table 3.2-1, Structures, Systems, Closed to future 5 feet of soil above it for tornado missile and freeze and Components That Are Designed to supplemental letter.

protection. Seismic and Tornado Criteria, lists the Fire Protection System Yard Hydrant

a. What is the licensing bases for the fire line Piping System as design such that it will buried depth related to tornado protection; not fail during a design tornado. UFSAR provide reference such as UFSAR section. Section 9.5.1 Fire Protection System, states that the fire protection 12 inch yard

b. Does this fire line meet this required depth, loop has a minimum cover of 5 feet for knowing the slope of the safety related dike. missile protection. Copies of the UFSAR descriptions are provided.

b. Field surveying on 7/17/19 confirmed the fire protection piping has approximately 6 to 7 feet of cover, and is located vertically below the dike crest, approximately 2 to 6 feet of the western edQe.

Table 2 NRC Audit- Attendees July 15, 2019 (Site Entrance)

Attendee Nam Agency Title Ed Miller NRC-NRR Project Manager Larry Wheeler NRC-NRR Technical Reviewer Audit Lead Hosung Ahn NRC-NRR Technical Reviewer Dan Hoana NRC-NRR Technical Reviewer Charles Rose Dominion Operations Don Taylor Dominion Manager - Licensing Mark Walker Dominion Manager - Site Engineering Stewart Morris Dominion Manager - Design Engineering John Slattery Dominion Manager - Operations James Jenkins Dominion Director - Safety and Licensing Dong Strulkmever Dominion Supervisor - Aux. Systems and Programs Dan Schoenster Dominion Supervisor - Civil/Mechanical Design Engineering Bob Paae Dominion Licensing Malcolm Hargraves Dominion Civil Engineering (Innsbrook)

Michael Bourdeau Dominion Engineering Table 3 NRC Audit - Attendees July 17, 2019 (On Site, Exit Briefing)

Attendee Name Agency Title Larry Wheeler NRC-NRR Technical Reviewer Audit Lead Hosung Ahn NRC-NRR Technical Reviewer Dan Hoang NRC-NRR Technical Reviewer Bob Page Dominion Licensina Eric Hendrickson Dominion Director - Engineering Don Tavlor Dominion Manaaer - Licensina James Jenkins Dominion Director - Safety and Licensing Dona Strulkmever Dominion Supervisor - Aux. Systems and Programs Gregory Meinweiser Dominion PRA (lnnsrook)

Malcolm Hararaves Dominion Civil Enaineerina (Innsbrook)

Michael Bourdeau Dominion Engineering Enclosure

ML19207A229 *Via E-mail OFFICE NRR/DORL/LSPB/PM NRR/DORL/LPL2-1/LA NRR/DE/ESEB/BC*

NAME GEMiller KGoldstein BWittick (GThomas for)

DATE 8/14/19 8/8/19 8/12/19 OFFICE NRR/DSS/SCPB/BC* NRO/DLSE/EXHB/BC* NRR/DORL/LPL2-1/BC NAME SAnderson DBarnhurst MMarkley DATE 8/13/19 8/12/19 8/16/19